Frontline Wireless wants the FCC to lower the reserve prices in the upcoming …

If you've ever seen the old car parts ad with the slogan, "I'm not going to pay a lot for this muffler!", then you have a pretty good sense of how Frontline Wireless feels about the reserve prices set by the FCC in the upcoming 700MHz spectrum auction. The company has just filed a paper (PDF) with the Commission in which it lays out its complaints about the auction rules, and "minimum price" is right at the top of the list.

Frontline, which counts two former FCC chairmen among its backers, wants to run the new public/private wireless network that must be built to public safety specifications and must give first responders priority access. It plans to pony up billions of dollars to build such a network; in return, it gets a guaranteed "anchor tenant" in public safety departments around the country, and it also gets the right to some extra spectrum over which it can offer private services.

Building a network to public safety specifications requires a far more robust infrastructure than a normal commercial network, and it requires an even better national footprint. Those things cost money. According to Frontline, the extra requirements of a public safety network will add at least $5 billion more to the normal cost of building out a new nationwide network.

Given the fabulous sums of money that could be required, Frontline argues that the FCC's proposed $1.3 billion reserve price for the D block of spectrum is far too high.

"Set at this high level, the prices will depress bidder interest and, coupled with the re-auction proposal, will incentivize strategic behavior by those who want us auction to fail, and thereby jettison the open access requirements and public safety sharing requirements," the group writes in its filing.

What Frontline is referring to here is the fact that the FCC has decided to run the auction again for specific blocks if the reserve prices aren't met, and it would also remove some of the restrictions currently imposed on different parts of the spectrum in order to make it more attractive to buyers. As Frontline points out, though, this could encourage those companies that want to get access to unencumbered spectrum to purposely let the auction fail. Setting the reserve price too high is one way to help make that happen.

Of course, Frontline has an obvious interest here that goes beyond concerns that the auction not fail: it wants to pick up the D block at the lowest possible price, use the prime spectrum to sell voice and data services to consumers and public safety groups, and then roll around in fat piles of cash.

The company has been a vociferous lobbyist at the FCC for its ideas throughout the entire year; in fact, Frontline did the most lobbying of any group interested in the auction and secured 3.5 times more meetings with FCC than did Google.

For its part, the FCC appears to be trying to head off accusations of another massive spectrum giveaway. Whether its new reserve prices will help or hinder this goal remains to be seen.